Wistin Abraham Galvan Lopez v. Kristi Noem, et al.

CourtDistrict Court, D. New Mexico
DecidedJanuary 30, 2026
Docket2:25-cv-01288
StatusUnknown

This text of Wistin Abraham Galvan Lopez v. Kristi Noem, et al. (Wistin Abraham Galvan Lopez v. Kristi Noem, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wistin Abraham Galvan Lopez v. Kristi Noem, et al., (D.N.M. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

WISTIN ABRAHAM GALVAN LOPEZ,

Petitioner,

v. No. 2:25-cv-1288 JB/DLM

KRISTI NOEM, et al.,

Respondents.

PROPOSED FINDINGS AND RECOMMENDED DISPOSITION

THIS MATTER is before the Court on Petitioner Wistin Abraham Galvan Lopez’s Petition for Writ of Habeas Corpus pursuant to 28 U.S.C. § 2241. (Doc. 1.) Galvan Lopez brings a claim for unlawful detention under the Immigration and Nationality Act (INA) and for a violation of his due process rights under the Fifth Amendment. He also filed a Motion for Temporary Restraining Order and Preliminary Injunction (TRO). (Doc. 4.) Having reviewed the record and relevant law, the undersigned recommends that the Petition be GRANTED and his Motion for Temporary Restraining Order and Preliminary Injunction be DENIED AS MOOT.1 I. Factual and Procedural Background Petitioner Galvan Lopez is a 22-year-old citizen and national of Guatemala. (Doc. 1 ¶ 13.) He entered the United States without inspection near Roma, Texas on August 10, 2019, when he was approximately 16 years old. (See id. ¶ 20; see also Doc. 4-6 at 2.) United States Border Patrol agents encountered him the same day and took him into custody after they determined he had entered unlawfully. (Doc. 4‑6 at 2.) Because he was an unaccompanied minor, Border Patrol

1 On December 29, 2025, United States District Judge James O. Browning entered an Order of Reference referring this case to the undersigned Magistrate Judge “to conduct hearings, if warranted, including evidentiary hearings, and to perform any legal analysis required to recommend to the Court an ultimate disposition of the case.” (Doc. 2.) processed him as an Unaccompanied Alien Child (UAC) and transferred him to the custody of the

Office of Refugee Resettlement (ORR) pursuant to 6 U.S.C. § 279 and 8 U.S.C. § 1232. (Doc. 1 ¶ 20; see also Doc. 4-6 at 2.) ORR later released him “to the care of loved ones in the United States.” (Doc. 1 ¶ 20.) After his release, Petitioner lived primarily in the Rochester, New York area, where he attended high school and later worked in construction. (Id. ¶ 22.) Petitioner has no criminal history. (Id. ¶ 21.) On March 24, 2025—more than five years after his initial release from Department of Homeland Security (DHS) custody—Immigration and Customs Enforcement (ICE) agents detained Petitioner in Rochester as “collateral” during an enforcement operation targeting another individual. (Id. ¶¶ 1, 21.) ICE subsequently transferred him to the Otero County Processing Center

(OCPC) in Chaparral, New Mexico and initiated removal proceedings on the basis that he was “present in the United States without being admitted or paroled, or . . . arrived in the United States at any time or place other than as designated by the Attorney General[]’” pursuant to INA § 212(a)(6)(A)(i), codified at 8 U.S.C. § 1182(a)(6)(A)(i). (Id. ¶¶ 6, 13; see also Docs. 4-1 at 1; 4-6 at 2.) Petitioner sought a custody redetermination under 8 U.S.C. § 1226(a). (See Doc. 1 ¶ 23.) On August 12, 2025, an Immigration Judge (IJ) found that he was detained under § 1226(a), determined that he was neither a danger to the community nor a flight risk, and granted bond in the amount of $5,000. (See id.; see also Doc. 4-3) “The same day, ICE filed a Form EOIR-43, unilaterally staying the IJ’s [bond] order” pending appeal. (Doc. 1 ¶ 24 (citing 8 C.F.R. §

1003.19(i)(2)); see also Doc. 4-4.) On October 23, 2025, the Board of Immigration Appeals (BIA) reversed the IJ’s decision,

concluding that Petitioner is subject to mandatory detention under 8 U.S.C. § 1225(b)(2)(A). (Doc. 1 ¶ 25; see also Doc. 4 at 2.) Petitioner has now been detained for more than nine months. (See Doc. 4 at 2.) On December 22, 2025, Petitioner filed a petition for writ of habeas corpus under 28 U.S.C. § 2241, asserting two claims arising from his continued detention: (1) violation of the INA and (2) violation of due process under the Fifth Amendment. (See Doc. 1.) He asks the Court to: (i) assume jurisdiction over this matter; (ii) issue a Writ of Habeas Corpus ordering Respondents to immediately release him from custody pending these proceedings; (iii) in the event that he is not released, order Respondents to Show Cause why the petition should not be granted; (iv) enjoin Respondents from transferring him away from the jurisdiction of this District pending these

proceedings; (v) declare that his detention violates the Due process Clause of the Fifth Amendment; (vi) award reasonable attorney’s fees and costs; and (vii) “[g]rant any further relief this Court deems just and proper.” (Id. at 7.) On January 11, 2026, Petitioner filed a Motion for Temporary Restraining Order and Preliminary Injunction seeking immediate release pending resolution of his habeas petition. (See Doc. 4.) The Federal Respondents filed their response in opposition to the TRO and the Habeas Petition on January 21, 2026. (Doc. 14.) On January 23, 2026, Respondent Dora Castro, Warden of the Otero County Processing Center, filed a notice joining the position taken by the federal Respondents. (Doc. 18.) That same day, Petitioner filed his Reply. (Doc. 19.) The matter is now fully briefed and ready for disposition.2

II. Legal Standard Federal courts possess longstanding authority to review the legality of executive detention through the writ of habeas corpus. 28 U.S.C. § 2241 expressly authorizes courts to issue a writ of habeas corpus when a person is “in custody in violation of the Constitution or laws or treaties of the United States.” 28 U.S.C. § 2241(c)(3). The Tenth Circuit has recognized that “[c]hallenges to immigration detention are properly brought directly through habeas.” Soberanes v. Comfort, 388 F.3d 1305, 1310 (10th Cir. 2004) (citing Zadvydas v. Davis, 533 U.S. 678, 687–88 (2001)). The fundamental purpose of a § 2241 habeas corpus proceeding is to allow a detainee to challenge the legality of his custody and to secure release from unlawful detention. See

Palma‑Salazar v. Davis, 677 F.3d 1031, 1035 (10th Cir. 2012). Because Petitioner challenges the legality of his continued detention, his claim falls squarely within the scope of § 2241. III. Discussion Petitioner contends that his continued detention is unlawful because DHS is detaining him under the wrong statutory provision in violation of the INA, and because his redetention without an individualized bond hearing violates the Due Process Clause. (See Docs. 1 at 6–7; 4 at 3–4.) Both arguments are well-grounded in the record and consistent with recent decisions scrutinizing DHS’s evolving detention practices. For the reasons set forth below, the undersigned concludes that § 1226(a)—not § 1225(b)(2)—governs Petitioner’s custody.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Soberanes v. Comfort
388 F.3d 1305 (Tenth Circuit, 2004)
Palma-Salazar v. Davis
677 F.3d 1031 (Tenth Circuit, 2012)
Zadvydas v. Davis
533 U.S. 678 (Supreme Court, 2001)
Jennings v. Rodriguez
583 U.S. 281 (Supreme Court, 2018)
Yajure Hurtado
29 I. & N. Dec. 216 (Board of Immigration Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
Wistin Abraham Galvan Lopez v. Kristi Noem, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/wistin-abraham-galvan-lopez-v-kristi-noem-et-al-nmd-2026.